A ‘‘payroll
customer’’ is any other person (i.e., a
person not otherwise covered under the
exempt person definitions) that: (A) Has
maintained a transaction account at the
bank for at least two months; (B)
operates a firm that regularly withdraws
more than $10,000 in order to pay its
United States employees in currency;
and (C) is incorporated or organized
under the laws of the United States or
a State, or is registered as and eligible
to do business within the United States
or a State.17 A payroll customer is an
exempt person ‘‘[w]ith respect solely to
withdrawals for payroll purposes"- Tips do not sound like payroll to me. I found this in a FinCen Release from 2009 about Payroll exemptions.
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Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney